Feb.18th, 2015 IABS, PMDA and JST joint Symposium Scientific Points to Consider: Starting Cells, Other Raw Materials, Manufacturing-Related Substances and Non-cellular Components Constituting the Complex Final Products Daisuke MAEDA, PhD Office of Cellular and Tissue-based Products Pharmaceuticals and Medical Devices Agency (PMDA), Japan Disclaimer: The views and opinions expressed here are those of the presenter and do not necessarily represent those of PMDA. Pharmaceuticals and Medical Devices Agency 1 Contents 1. Overviews of materials for manufacturing 2. Starting materials 3. Other raw materials and manufacturingrelated substances 4. Non-cellular components constituting the complex final products Pharmaceuticals and Medical Devices Agency 2 Contents 1. Overviews of materials for manufacturing 2. Starting materials 3. Other raw materials and manufacturingrelated substances 4. Non-cellular components constituting the complex final products Pharmaceuticals and Medical Devices Agency 3 Manufacturing Process of CTPs Collection of Cell Source Starting cells Raw Materials Culture (amplification) Raw Materials Cell Bank/ Cell Stock Culture (differentiation) Manufacturing-Related Substances Raw Materials Manufacturing-Related Substances Filling (Cryopreservation) Excipients Manufacturing-Related Substances Final Product Pharmaceuticals and Medical Devices Agency 4 Case of Autologous Cultured Epidermis JACE (MAA: 29th Oct. 2007 ) Collection of Cell Source Patient’s skin Starting cells Culture (amplification) Cell Stock Culture flask ・・・ManufacturingRelated Substances Filling Carrier, Cover sheet ・・・ManufacturingRelated Substances Final Product Pharmaceuticals and Medical Devices Agency ・・・Source Tissues Protease/ collagenase Culture media FBS Feeder cells Recombinant insulin Human EGF Cholera toxin Antibiotics Trypsin Dulbecco's PBS Storage buffer Raw Materials ・・・Excipients Excerpt from Review Report on JACE, http://www.pmda.go.jp/english/service/p df/medical_devices/jace_oct2007_e.pdf 5 Categorization of Materials Used in Manufacturing Raw Materials Human and animal-derived Manufacturing-Related substances Non animal-derived Starting materials Tissues, Cells FBS, Human Serum, HSA, Feeder Cells, Trypsin, Heparin Culture media Recombinants (animal-free) Antibiotics D-PBS Culture dishes/ flasks, Columns, Filters, Vessels, Tubing, Bags Excipients/ Non-cellular components of final products Collagen matrix Storage buffer, Scaffolds, Sponge, Support membranes, Fibers Pharmaceuticals and Medical Devices Agency 6 What’s “Ancillary Materials” ? No Japanese equivalent for “Ancillary Material” as a legal term. Ancillary materials (AMs) include a wide variety of raw materials and materials used in process, are used to ensure the safety, effectiveness, and consistency of the final product, come into contact with the cells or tissues during manufacturing, are not intended to be part of the final product formulation. Materials or components that are intended to be in the final product dosage form are not AMs. → USP General Information <1043> Ancillary Materials Pharmaceuticals and Medical Devices Agency 7 Categorization of Materials Used in Manufacturing Raw Materials Human and animal-derived Manufacturing-Related substances Non animal-derived Starting materials Tissues, Cells Ancillary materials FBS, Human Serum, HSA, Feeder Cells, Trypsin, Heparin Culture media Recombinants (Animal-free) Antibiotics D-PBS Culture dishes/ flasks, Columns, Filters, Vessels, Tubing, Bags Excipients/ Non-cellular components of final products Collagen matrix Storage buffer, Scaffolds, Sponge, Support membranes, Fibers Pharmaceuticals and Medical Devices Agency 8 Assurance of Product Quality Design Quality Procedure Process Material Equipment Product Quality Quality Management Quality Risk Management / Knowledge Control Product Quality is affected by various factors. Better understanding the variables in the process, leads to good quality control. Pharmaceuticals and Medical Devices Agency 9 Quality of Materials for Manufacturing in the Control Strategy ICH-Q10 Input Manufacturing process Control Procedural controls Output on end-product • Sequence of • Release testing processing steps Output Control on material attributes • Starting cells • Raw materials Input • Excipients • Primary packaging materials etc. In-process control Parametric control In-process control In-process testing Pharmaceuticals and Medical Devices Agency 10 Contents 1. Overviews of materials for manufacturing 2. Starting materials 3. Other raw materials and manufacturingrelated substances 4. Non-cellular components constituting the complex final products Pharmaceuticals and Medical Devices Agency 11 Points to Consider for Starting Materials Source and Selection of Human Cells/ Donors 2. Donor Eligibility ・Test for the infectious diseases ・Information about clinical history 3. Collection, Storage, and Transport of Cells and Tissues 1. Pharmaceuticals and Medical Devices Agency 12 1. Source and Selection of Human Cells/ Donors Characteristics in biological structure/function of the starting cells/tissue should be provided by appropriately selected parameters such as ・morphological characteristics ・growth characteristics ・biochemical and immunological parameters ・HLA typing ・other relevant genotypic or phenotypic markers. Reasons for selection of the cell/tissue should be provided. Pharmaceuticals and Medical Devices Agency 13 2. Donor Eligibility Criteria When collecting human cell / tissue material, depending on the purpose of their use, relevant bacterial, fungal and viral infections have been denied through interviews, screening tests. The test parameters and methods used should be justified in light of the latest knowledge of infectious diseases, etc.. The donor’s clinical history of having received blood transfusion or transplantation must be taken into consideration when determining donor eligibility. Pharmaceuticals and Medical Devices Agency 14 2. Donor Eligibility Criteria (continued) According to the test parameters and methods, the re-testing and other infection controls at the right time should been made, taking into consideration the window period. However, it does not necessarily require a donor screening when the donor is the same person as the recipient (autologous). Pharmaceuticals and Medical Devices Agency 15 Autologous C/T vs Allogeneic C/T Autologous Human Cells/Tissues Infectious status of donor, including infections of HBV, HCV, HIV, and HTLV. Risk of viral replication or re-activation in manufacturing processes Robust process control to minimize unevenness of “custom-made” products Limited amounts of samples for quality evaluation of products Pharmaceuticals and Medical Devices Agency Allogenic Human Cells/Tissues History, source, derivation Donor screening/testing and donor eligibility (compatibility with donor qualification criteria, including ethical and medical aspects; freedom from the presence of HBV, HCV, HIV, HTLV and parvovirus B19 by screening and testing; exclusion of potential infection of CMV, EBV and WNV by testing; clinical history; experience of blood transfusion or implanting; genetic variants etc.) Records of donor Derivation of cell strain Cell banking Viral assays at the final product level Immunological relevance 16 2. Donor Eligibility Criteria (continued) Donor Recordkeeping The records of donors should be maintained and stored so as to verify information required to secure safety of the cell and tissue as materials. For each experimental sample of the donor and the patient, the content of information and its storage measure may depend on the intended use. Pharmaceuticals and Medical Devices Agency 17 3. Collection, Storage, and Transportation of Cells and Tissues (1) Eligibility of medical professionals and institutions collecting the samples (2) Suitability of the sampling site and method (3) Interviews or tests to ensure donor safety (4) Informed consent for donors (5) Protection of donor privacy (6) Storage methods and measures to prevent erroneous sampling (mix-up) (7) Transportation methods (8) Preparation of records for (1)-(7) and record-keeping procedures Pharmaceuticals and Medical Devices Agency 18 Contents 1. Overviews of materials for manufacturing 2. Starting materials 3. Other raw materials and manufacturingrelated substances 4. Non-cellular components constituting the complex final products Pharmaceuticals and Medical Devices Agency 19 Categorization of Materials Used in Manufacturing Raw Materials Human and animal-derived Manufacturing-Related substances Non animal-derived Starting materials Tissues, Cells Ancillary materials FBS, Human Serum, HSA, Feeder Cells, Trypsin, Heparin Culture media Recombinants (animal-free) Antibiotics D-PBS Culture dishes/ flasks, Columns, Filters, Vessels, Tubing, Bags Excipients/ Non-cellular components of final products Collagen matrix Storage buffer, Scaffolds, Sponge, Support membranes, Fibers Pharmaceuticals and Medical Devices Agency 20 Impact of AMs on Quality and Safety of CTPs The quality of AMs is very important to ensure the stability, safety, potency and consistency of CTPs as following; The precise mechanism by which an AM exerts its effect may not be known. The impact of variations of the AM on the quality and safety of the final product may not be understood. AMs of human or animal origin may present an infectious disease transmission risk. Some AMs may elicit an immune reaction to the human. Some AMs have toxic properties. The risks attributed to the quality of AMs on the quality and safety of CTPs are often increased due to the limited ability to conduct extensive in-process and release tests. Pharmaceuticals and Medical Devices Agency 21 Qualification Whenever possible, it is preferable to use AMs that are approved as drugs because they are well characterized, have an established toxicological profile, and are manufactured according to controlled and documented procedures. Conversely, the AM “for research use only” may not satisfy the level of qualification necessary for use in the production of a therapeutic product. In either case, CTPs should be developed with comprehensive and scientifically sound qualification plans to ensure the traceability, consistency, suitability, purity, and safety of the AM. Pharmaceuticals and Medical Devices Agency 22 USP’s risk-based approach USP General Information <1043> Ancillary Materials for Cell, Gene, and Tissue-Engineered Products Tier Risk Properties of materials 1 Low highly qualified materials with intended use as therapeutic drugs or biologics, medical devices, or implantable materials (e.g. heparin for injection) 2 Low well-characterized materials with intended use as AMs, produced in compliance with GMPs 3 Moderate materials not intended for use as AMs (frequently produced for in vitro diagnostic use or reagent-grade materials) 4 High High-risk materials(e.g., FBS, animal-derived(including human) extracts, animal or human cells used as feeder layers, chemical entities with known toxicities) Pharmaceuticals and Medical Devices Agency 23 USP’s risk-based approach (continued) F. Atouf et al, BioProcess International 11(8) 12-21, 2013 Pharmaceuticals and Medical Devices Agency 24 Human and Animal-Origin Raw Materials (except Starting Materials) The source is to be clarified. Efforts are to be made to reduce the risk of infection for adventitious agents; minimize their amounts used explore alternative substances or sources (i.e., plant or chemically synthesized). ensure donor’s and donor animal’s health The manufacturing process is to be evaluated on the potentials to eliminate/inactivate adventitious agents Records in manufacturing are to be kept to ensure their traceability. Pharmaceuticals and Medical Devices Agency 25 Selection of Bovine Serum (as an example) Types of bovine serum Origin(country, strain) Vendor Grade Lot size available Pharmaceuticals and Medical Devices Agency 26 Guidelines for Bovine Serum EMA GL on the use of bovine serum in the manufacture of human biological medicinal products(30 May 2013, EMA/CHMP/ BWP/457920/2012 rev.1) US Pharmacopoeia <1043> Ancillary Materials <1024> Bovine Serum <90> FBS Quality Attributes and Functionality Tests Pharmaceuticals and Medical Devices Agency 27 Other Raw Materials • Culture media (composition) • Recombinant growth factors, cytokines (animal- free) • Monoclonal antibodies for cell sorting/purification • Antibiotics Pharmaceuticals and Medical Devices Agency 28 Selection of Raw Materials Select the materials on a risk-based approach based on own/existing knowledge for the product, referring to literatures and GLs, and then, Provide the rationale for their selection and the quality control to your competent authorities, and consult with them. Pharmaceuticals and Medical Devices Agency 29 Manufacturing- Related Substances • • • • Culture dishes Columns Filters Bags • Leacheables / Extractables • Foreign matter Pharmaceuticals and Medical Devices Agency 30 Contents 1. Overviews of materials for manufacturing 2. Starting materials 3. Other raw materials and manufacturingrelated substances 4. Non-cellular components constituting the complex final products Pharmaceuticals and Medical Devices Agency 31 Categorization of Materials Used in Manufacturing Raw Materials Human and animal-derived Manufacturing-Related substances Non animal-derived Starting materials Tissues, Cells Ancillary materials FBS, Human Serum, HSA, Feeder Cells, Trypsin, Heparin Culture media Recombinants (animal-free) Antibiotics D-PBS Culture dishes/ flasks, Columns, Filters, Vessels, Tubing, Bags Excipients/ Non-cellular components of final products Collagen matrix Storage buffer, Scaffolds, Sponge, Support membranes, Fibers Pharmaceuticals and Medical Devices Agency 32 Points to Consider on Non-cellular Components 1. In case of bio-absorbable materials, perform the necessary tests for the safety of the degradation products. 2. Evaluate the consequences of interactions between non-cellular components and cells: (a) any deleterious effects on the function, growth activity, or stability of the cells (b) any potential mutation, transformation, and/or dedifferentiation of the cells (c) no loss of the expected properties of the non-cellular components Pharmaceuticals and Medical Devices Agency 33 Take-home Messages Quality of the materials is one of the critical factors and should be determined on caseby-case basis approach depending on the characteristics of the product and its control strategy as a whole. Pharmaceuticals and Medical Devices Agency 34 Take-home Messages (continued) As for starting materials; Donor eligibility criteria are key elements; infectious agents. Reasons for selection of the cell/tissue should be provided with its desired/ targeted cell profile. The characteristics of their structure and biological function should be shown. Appropriate handling and processing is required. Pharmaceuticals and Medical Devices Agency 35 Take-home Messages (continued) As for other materials; Adequacy of using other raw materials and manufacturing-related substances should be shown, and it is necessary to perform appropriate quality control with defined acceptance criteria. Non-cellular components constituting the final products should be justified in term of the quality and the safety of CTPs. Appropriate/ sufficient information should be collected and provided. Pharmaceuticals and Medical Devices Agency 36 PMDA Pharmaceutical Affairs Consultation on R&D Strategy Strategic Consultation Clinical Use Basic Research Pharmaceuticals and Medical Devices candidates Quality Study NonClinical Study Consultation on quality or toxicity study of biologics, or cellular therapy products Pharmaceuticals and Medical Devices Agency Clinical Trial Innovative Products Consultation on endpoints or sample size of early clinical trial 37 Thank you for your kind attention! Pharmaceuticals and Medical Devices Agency 38
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